WHITESPACE REGIONAL AREA NETWORKS ALLIANCE (WRAN ALLIANCE) RESPONSE TO THE INDUSTRY CANADA CONSULTATION ON A POLICY AND

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1 WHITESPACE REGIONAL AREA NETWORKS ALLIANCE (WRAN ALLIANCE) RESPONSE TO THE INDUSTRY CANADA CONSULTATION ON A POLICY AND TECHNICAL FRAMEWORK FOR THE USE OF NON-BROADCASTING APPLICATIONS IN THE TELEVISION BROADCASTING BANDS BELOW 698 MHZ (CANADA GAZETTE NOTICE, SMSE , AUGUST 2011) COMMENTS OF THE WRAN ALLIANCE 1. WRAN Alliance respectfully submits these responses to the Industry Canada consultation. 2. The Whitespace Regional Area Network Alliance (WRAN Alliance - ) promotes the development, deployment and use of standards-based products and services as a means of providing broadband services especially in wide regional areas using whitespaces in general, with television band frequencies as a particular example. Our Goals are: a. Develop the standards and specifications necessary to allow companies to provide broadband connectivity at reasonable cost in rural and developing areas as a means to bridge the digital divide. b. to ensure interoperability between products regardless of manufacturer or origin c. to provide certification and testing of the devices implemented based on the technical protocols adopted by the WRAN Alliance d. to provide database compliance and interoperability for devices. e. to improve deployment and operating practices in the high speed wireless internet industry through education and support programs, and ultimately, to benefit page 1

2 consumers 3. WRAN Alliance has decided to create its first specification based on the IEEE Standard, published on July 1 st INTRODUCTION 4. First and foremost, we would like to commend Industry Canada for considering the licenseexempt usage of Television White Spaces (TVWS). We believe that effective use of TV band spectrum by services using licensed-exempt devices offers opportunities for growth in a wide range of applications in all sectors of the economy, including consumer, business, smart building, smart energy, to name a few. 5. The WRAN Alliance will be initially focused on promoting the use of the IEEE Standard for Wireless Regional Area Networks, in variety of different regulatory domains and for a variety of different use cases. Such use cases include broadband access over large distances with Line of Sight and Non Line-of-Sight conditions, broadband access for remote and rural areas, live-stock monitoring, monitoring of the rain-forests, long-range backhaul, smart grid and critical infrastructure monitoring, homeland security, healthcare, small office home office, campus wide broadband wireless access and a variety of others. 6. The IEEE Working Group ( dealing with cognitive radio based Wireless Regional Area Networks (WRANs) seeks to bring wireless broadband access primarily to rural and remote areas using TVWS. The IEEE Standard (TM) was published in July As a result of this work, the IEEE Working Group is the recipient of the 2011 IEEE Standards Association Emerging Technology Award. The IEEE Working Group has also published the IEEE (TM) standard for page 2

3 enhanced protection of low power licensed devices operating in TV bands (e.g., wireless microphones). 7. IEEE P project is developing a recommended practice for the installation and deployment of wireless regional area networks in the TV bands. 8. IEEE P802.22a Project is developing enhanced Management Information Base and Management Plane Procedures that will help in controlling and managing the TV Band devices as well as access to a database service that is being proposed in many administrations. RESPONSES TO QUESTIONS Question 6-1: Comments are sought on the benefits that could be expected from making white space available in Canada. See Page 8, Paragraph We believe the following benefits would result from making white space available in Canada: It could offer a more cost effect way to helps satisfy the growing demand for rural broadband services and could bridge the very real digital divide that currently exists between rural and urban areas. Besides the spectrum set aside for smart grid use in Canada, TV white space is an additional spectrum resource for these and other applications. Owing to its excellent propagation characteristics, many machine-to-machine applications such as critical infrastructure monitoring, or other low data rate communications such as livestock monitoring, etc, could benefit as well. Making the TV White Space spectrum license-exempt, in addition to lightly licensed (i.e., RRBS) permits flexible spectrum sharing and better use of the TV white space\ page 3

4 spectrum resource as new innovations & applications evolve in the market place. Superior propagation characteristics and better building penetration are available at these frequencies which will ensure robust operation in difficult terrain. Question 6-2: Comments are sought on the benefits of the above-mentioned innovation to manage interference. 10. We fully support the use of databases to protect the interests of licensed services, in particular database designs including timely, flexible reactive capabilities. 11. IEEE protocol was developed in consultation with the Television Broadcasters and it has all the capabilities required by law to avoid harmful interference to incumbents users of TV-band spectrum. These capabilities include: a. Access to incumbent database information using primitives that are included in the IEEE standard b. Spectrum sensing and all the associated Medium Access Control (MAC) messaging and quiet period scheduling. Support for a variety of spectrum sensing techniques is included in the standard since we believe that sensing is essential for not only protecting the incumbents, but also to enable co-existence between disparate devices. c. The ability to use various Regulatory-dependent spectrum policy sets as well as channel set management for the operating channel and backup channels to allow automatic channel switching that is transparent to the subscriber d. User terminal EIRP fully controlled by the base station: IEEE is capable of taking inputs about maximum EIRP from the database and apply it to the operation of its terminals. To make this operation full-proof, an antenna hardware and firmware interface has been defined for the antenna to provide its maximum gain to page 4

5 the attached terminal so that the EIRP and not only the conducted transmit RF power can be safely controlled even if different antennas are used. e. Accurate geolocation using inherent characteristics of the transmitted signals through advanced terrestrial geo-location techniques is included in the standard. 12. Self co-existence: IEEE protocol provides co-existence among systems operating in the same area through two mechanisms a. Spectrum etiquette mechanism when more than one channel is available, by choosing channels that are not already in use by other systems and b. On-demand frame contention when more than one system needs to share the same channel. Additional capabilities needed for database operation: 13. It is expected that without an area specific active channel management mechanism (e.g., spectrum manager), it is unlikely that having the database just specifying which channels are available to protect incumbent services on a periodic basis will be sufficient to allow for proper operation of different types of White Space Devices (WSDs) in an area without interference being caused among themselves. WRAN Alliance recommends that the database should be capable of keeping track of the channels that are currently being utilized by the master devices and the technology that they use (e.g., IEEE , IEEE af, etc.). If a request for the available channel is made by another master WSD from the same area and it is found that the new requesting master device technology cannot co-exist, then that channel should be removed from the available channels list being sent to this new device. Unless the given master WSD fails to re-query within the specified contact period, the database should make that channel available. The database interface protocol should also provide the master WSDs with a means to release their operating channel when not needed. page 5

6 The WRAN Alliance is of the opinion that the database can be a great tool to enable coexistence amongst license-exempt devices beyond protecting broadcast incumbents. Question 6-3: Comments are sought on the above proposed approach of setting technical standards now with respect to database dependent systems, and developing standards with respect to spectrum sensing devices when that technology has matured. 14. Spectrum sensing could be useful to protect licensed services in cases where a licensed service requires spectrum on short notice (e.g., news crews on remote assignments using licensed wireless microphones). Sensing, or use of beaconing, could be a reliable way for spectrum sharing while ensuring that the incumbent services are protected. 15. In some regulatory domains (e.g., CEPT, European Union), consideration is being given to increasing the sensing threshold in the case where collaboration amongst sensing WSDs, based on their geographic placement, takes place to improve sensing reliability. Such relaxation of the sensing threshold would render RF sensing more easily feasible. 16. Spectrum sensing will also benefit inter-system co-existence and hence better usage of the spectrum. 17. For the above reasons, WRAN Alliance supports the suggested approach of utilizing databases for now however, creating a time-frame when WSDs will be matured to have capabilities such as sensing with appropriate thresholds. Question 6-4: Comments are sought on these proposed provisions related to database performance and operation. Would these provisions provide sufficient capability to respond to interference cases or other problems that might occur once the white space page 6

7 devices are in use? Are there any additional provisions that Industry Canada should adopt? 18. We believe that the proposed provisions have correctly specified how this can be done today with proper protection of incumbents in the band, with only a few exceptions. We present these exceptions as follows. 19. The uncertainty (meters) and confidence level (e. g., 95% as suggested by UK Ofcom) should be verified by an official organization during device testing and certification of a WSD. The confidence level should not be a variable dependent on individual WSD performance, nor determined autonomously by the WSD or WSD network. 20. The TV bands database system plan and operation should be augmented to allow online, near real-time operation. We believe that database push functionality, as well as pull functionality, should be a requirement. 21. Further conditions pertaining to location verification, possibly by technological capabilities or by legal certification of responsibility, should be specified so that a WSD can determine if it has moved a significant distance. 22. Querying of the database by a base station on behalf of its associated user terminals should be allowed since the selection of the operating channel and backup channels should be done at the base station as being the channels that are available to most of its terminals. Sending such information directly to the terminals would not allow such search for commonly available channels. 23. The WSD should be required to supply a certification of identity in order to be granted operational access by the database. Reciprocally the database should be required to supply a certification of identity in order for the WSD to ascertain that the WSD is being controlled by an officially approved database. This will ensure mutual authentication to avoid spoofing or Denial of Service (DoS) attacks. page 7

8 24. We suggest that security related issues should be adequately considered in database implementation. The security aspects include ensuring database availability, authorization to access, authentication, encryption, data integrity, non-repudiation, confidentiality and privacy. 25. With respect to security, integrity, authentication, and related issues mentioned above, WRAN Alliance has concerns with the statements that the database could reside in Canada or elsewhere and Industry Canada would not regulate the development, management or internal operation of such databases or the exchange of data between different database administrators, and would not establish requirements for open access, security or reliability. We believe that these kinds of issues should remain within the regulatory domain of the Canadian government. 26. It is expected that without an area specific active channel management mechanism (e.g., spectrum manager), it is unlikely that having the database just specifying which channels are available to protect incumbent services on a periodic basis will be sufficient to allow for proper operation of different types of White Space Devices (WSDs) in an area without interference being caused among themselves. WRAN Alliance recommends that the database should be capable of keeping track of the channels that are currently being utilized by the master devices and the technology that they use (e.g., IEEE , IEEE af, etc.). If a request for the available channel is made by another master WSD from the same area and it is found that the new requesting master device technology cannot co-exist, then that channel should be removed from the available channels list being sent to this new device. Unless the given master WSD fails to re-query within the specified contact period, the database should make that channel available. The database interface protocol should also provide the master WSDs with a means to release their operating channel when not needed. page 8

9 The WRAN Alliance is of the opinion that the database can be a great tool to enable coexistence amongst license-exempt devices beyond protecting broadcast incumbents. Question 6-5: Comments are sought on the above categories. 27. Types of WSD - The term mobility may imply high speed mobile operation which is an important value addition but may not allow robust protection of the incumbents. Hence the term nomadic or portable may be needed to differentiate it from fully mobile terminals as operated in other wireless system instances. Question 6-6: Comments are sought on these proposals. 28. We have no comments at this time. Question 6-7: Comments are sought on the above proposal to broadly harmonize technical rules with those in the United States. Considering the potential benefits of such harmonization, are there areas where Canada should consider variations from the U.S. technical rules? 29. Although having harmonized technical rules may be desired, there are certain aspects that can be included which will enable wider and safer deployments of WSDs. These are specified below: 30. Spectrum Mask Considerations: A spectrum mask as proposed by Industry Canada for Remote Rural Broadband Service (RRBS) for lightly licensed operation is more practical to meet than the one that has been proposed in the United States regulations. However, the fact that Canada does not allow operation on co-channel and first and second adjacent channels page 9

10 is likely to result in inefficient spectrum use. We support the concept of a more intelligent database service that considers the device capabilities (e.g., spectrum mask) to calculate appropriate separation distances and the specification of maximum EIRP by the database for given operational conditions such as known separation distance from a protected contour. 31. Spectrum sensing: In United States, spectrum sensing is no longer a requirement. The current US rules specify a class of low power sensing only devices where the transmit power has been restricted to 50 mw. However, as indicated earlier, sensing does have its benefits if relaxed sensing thresholds can be used in the case of collaboration amongst properly spaced sensing devices. 32. HAAT: The HAAT of 76 m as proposed in the FCC rules will preclude TVWS operation in many parts of the US. We recommend making HAAT an input parameter to the database so that it can be related to the maximum EIRP allowed for the terminal as in the case of RRBS. 33. Maximum EIRP: We support the concept of database control of the maximum allowed EIRP per TV channel based on device characteristics and operational context. Question 6-8: Comments are sought on the interference protection criteria for TV broadcasting operations. Are the provisions in Table 6.2 adequate to ensure the protection of over-the-air TV broadcasting services? Should provision be made for white space devices using power control to have additional flexibility in selecting frequencies, as has been proposed in the United Kingdom? 34. Please see response to Question 6-7 with respect to control of the maximum EIRP by the database. page 10

11 Question 6-9: Comments are sought on the potential for improvements to the policy and technical framework for RRBS, including the possibility of moving to a licence-exempt regime, leveraging white space technology. 35. We support the idea of providing grandfather protection to the deployed RRBS systems in Canada, and maintaining their licensed status with their operation registered in the database service to assure protection from interference from license-exempt devices. This will ensure that the RRBS can continue to provide their services in rural areas without any disruptions. We believe that the current RRBS program should not be phased out and allow new applications to be granted if these can facilitate deployment of broadband access services in under-served areas. Question 6-10: Should Industry Canada identify specific spectrum for use by LPA? If so, how much should be identified and should the operation of licence-exempt LPA be restricted to this spectrum? 36. The WRAN ALLIANCE believes that identifying a dedicated spectrum for wireless microphone operation is a good idea. Question 6-11: Comments are sought on the options for the authorization of LPA in Canada. Provide justification for this choice of option. 37. We believe that Option 1 is synonymous with granting amnesty to unauthorized microphone users. page 11

12 38. Option 2 has been recommended in the United States rules but there are issues with database registration where the 24 hours grace period is too long. This is where a push technology for the database interface would be of great interest. 39. We do not support Option 3 since that will result in license-exempt microphones operating on all possible channels with the possibility that WSDs and microphones would suffer from mutual interference. 40. Option 4 is a new concept where LPAs will become new WSDs. This may be considered in the future. 41. Hence, out of all the options, we support the idea of Option 5 as the safest option. Question 6-12: If option 1, 2 or 5 is chosen, comments are sought on the proposal to collect time and location of use data based on voluntary registration and the proposal that eligibility to register for such protection be open to all users of LPA. Comments are also sought on the appropriate protection criteria to protect LPA from interference from white space devices. 42. We believe that all LPAs should operate on a licensed basis. Protection of LPAs should be provided by the database implementation. Question 6-13: Comments are sought on the above proposals. Should provisions for flexible out-of-band masks, similar to the U.K. rules, also be included? Is there a need for additional measures on adjacent channels to protect systems operating at the edge of the TV bands? page 12

13 43. We support the idea of including flexible out-of-band masks to protect systems operating on adjacent channels. We recognize however that the regulator will have the last word on allowing or not allowing the operation of WSDs on their territory based on the out-of-band performance of such WSDs as it relates to efficient use of the spectrum (i.e., regulator may forbid the operation of WSDs that do not meet minimum out-of-band rejection requirement by sending empty available channel list or very low maximum EIRP per channel as a result of a query). Question 6-14: On balance, do the potential benefits of permitting licence-exempt white space devices to operate in Canada outweigh their potential risks to other services? 44. Yes. Question 7-1: Comments are sought on these proposed modifications to the Canadian Table of Frequency Allocations. 45. We have no comments at this time. Question 8-1: Comments are sought on whether the measures of the FCC to protect Canadian licensees are adequate and whether Industry Canada s proposed measures are adequate to protect U.S. licensees, including TV broadcasters. Provide supporting arguments for your response. 46. We have no comments at this time. page 13

14 CONCLUSION 47. WRAN ALLIANCE supports Industry Canada s efforts in this proceeding to establish the regulatory framework for licensed-exempt technology in the Canadian TV bands. We believe that moving forward to open up TV spectrum to the kinds of devices and applications that have been so successfully deployed in the better established license exempt bands like 2.4 GHz and 5 GHz will bring economic and social benefits to the people of Canada. Respectfully submitted, /s/ Dr. Apurva N. Mody (Chair, WRAN Alliance, apurva.mody@wranalliance.org), Ivan Reede (Vice Chair, WRAN Alliance, ivan.reede@wranalliance.org), Dan Lubar (Board Member, WRAN Alliance, dan.lubar@wranalliance.org) Whitespace Regional Area Networks 2400 Camino Ramon, Suite 375 San Ramon, CA, References [1] IEEE (TM) Standard. ( [2] US FCC, ET Docket : Notice of Inquiry, In the Matter of Additional Spectrum for Unlicensed Devices Below 900MHz and in the 3GHz Band, Released December 20, 2002 page 14

15 [3] US FCC, ET Docket : Notice of Proposed Rule Making, In the Matter of Unlicensed Operation in the TV Broadcast Bands, Released May 25, 2004 [4] IEEE Std TM-2009, Standard for Information Technology Telecommunications and Information Exchange Between Systems Local and Metropolitan Area Networks Specific Requirements Part 22.1: Enhanced Protection for Low-Power, Licensed Devices Operating in Television Broadcast Bands, November [5] US FCC, ET Docket : First Report and Order and Further Notice of Proposed Rule Making, In the Matter of Unlicensed Operation in the TV Broadcast Bands, Released October 18, [6] U.S. FCC, ET Docket , Second Report and Order and Memorandum Opinion and Order in the Matter of Unlicensed Operation in the TV Broadcast Bands, November 14, page 15

DSA Response: Ofcom Consultation on Manually Configurable White Space Devices

Dynamic Spectrum Alliance Limited 21 St Thomas Street 3855 SW 153 rd Drive Bristol BS1 6JS Beaverton, OR 97003 United Kingdom United States http://www.dynamicspectrumalliance.org DSA Response: Ofcom Consultation